PRIVACY POLICY
INTRODUCTION
MEMORY CARD ARCADE LIMITED ("we", "us", or "our") operates the Philo Fragment mobile application (the "Service").
This page explains how we collect, use, disclose, and protect personal data when you use our Service, and the choices you have regarding that data.
Use of the Service is subject to this Privacy Policy.
WHO WE ARE
- Controller: MEMORY CARD ARCADE LIMITED
- Registered address: Unit A 82-82D James Carter Road, Mildenhall BURY ST. EDMUNDS, IP28 7DE United Kingdom
- Privacy contact: [email protected]
INFORMATION COLLECTION AND USE
PURPOSES & LEGAL BASES (EU/UK)
| Purpose | Examples | Legal basis |
|---|---|---|
| Provide and maintain the Service | Account creation, features, transactions | Contract (Art. 6(1)(b)) |
| Security & fraud prevention | Authenticate, prevent abuse | Legitimate interests (Art. 6(1)(f)) and/or Legal obligation (Art. 6(1)(c)) |
| Analytics | Measure usage, improve features | Consent for non-essential cookies/SDKs; limited legitimate interests only where permitted without tracking |
| Marketing communications | Newsletters, product updates | Consent (you may withdraw at any time) |
| Personalized ads | Cross-context behavioral advertising | Consent (EU/UK). California: opt-out of sale/share |
| Compliance | Tax, accounting, legal requests | Legal obligation (Art. 6(1)(c)) |
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
We do not collect personal information that you directly provide to us. However, we may automatically collect certain technical and usage data as described below.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a device ("Usage Data"). Usage Data may include information such as your device's Internet Protocol (IP) address, browser type and version, device identifiers, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.
SDKs and Similar Technologies
Our mobile app uses SDKs, pixels and similar technologies. We may use these for analytics, personalization, crash reporting, or advertising purposes in accordance with applicable law. You may limit tracking via your device settings.
Sources of Personal Data
- You: Information you provide (e.g., forms, account, support).
- Device & browser: Technical and usage data (e.g., IP address, device identifiers, logs). Non-essential cookies/SDKs are used only with consent where required.
USE OF DATA
MEMORY CARD ARCADE LIMITED uses the collected data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
RETENTION
We keep personal data only as long as necessary for the purposes described or as required by law. Where specific periods are not feasible, we apply clear criteria (e.g., account lifetime + a defined period, statutory limitation periods). Cookies and SDKs have varying retention periods depending on their purpose.
DELETE OR UPDATE YOUR DATA
Where available, you may update certain information within your account settings. You may also request that we delete Personal Data we hold about you, subject to legal exceptions (for example, if we must retain data to comply with law).
YOUR CHOICES
- Control tracking through your device settings (reset/limit advertising ID, disable location access, etc.).
- Disable push notifications in the app or device settings.
- Opt out of marketing emails via the unsubscribe link or by contacting us.
- California residents: use our Do Not Sell or Share and Limit SPI options where applicable.
INTERNATIONAL TRANSFERS
Personal data may be transferred to and processed in countries outside the EEA or UK. Where such transfers occur, we use appropriate safeguards such as the EU Standard Contractual Clauses (Commission Decision (EU) 2021/914) and/or the UK International Data Transfer Agreement/Addendum, and we carry out transfer risk assessments with supplementary measures where appropriate.
Our hosting and service providers may be located in various jurisdictions. We ensure that all data processors maintain adequate data protection standards.
Service Providers and Affiliates
We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. We may also share information with our affiliates, in which case we require them to honor this Privacy Policy. These third parties have access to Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Typical categories of recipients include cloud hosting, analytics, advertising/remarketing partners (where enabled), payment processors, customer support platforms, and security/fraud-prevention vendors.
Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Legal Requirements
MEMORY CARD ARCADE LIMITED may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of MEMORY CARD ARCADE LIMITED
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of users of the Service or the public
- Protect against legal liability
SECURITY OF DATA
We implement appropriate technical and organizational measures to protect your Personal Data. While no method of transmission or storage is 100% secure, we continuously improve our safeguards.
AUTOMATED DECISION-MAKING
We do not make decisions based solely on automated processing that produce legal or similarly significant effects. If this changes, we will provide required information about the logic involved and your rights.
LINKS TO OTHER SITES
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
CHILDREN'S PRIVACY
Our Services are not directed to children. For EU/UK users, where we offer information society services and rely on consent, we obtain parental consent for users below the applicable age (EU up to 16; UK 13). If you believe a child has provided data contrary to this policy, contact us to request deletion.
CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
CONTACT US
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:
- Privacy requests: [email protected]
- By email: [email protected]